COMMUNITY CHOICE AGGREGATION
IMPLEMENTATION PLAN DEVELOPMENT
PCE Project Advisory Committee
January 28, 2016
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CCA Implementation Plan: Overview
The Plan is:
• A statutory requirement: Public Utilities Code, Section 366.2.(c)(3)
• Provides detail regarding process and consequences of aggregation
• A document that must be considered and adopted at a public hearing
• A document that must be submitted to (and certified by) the CPUC
The Plan is not:
• A detailed business plan for all intended programs of the CCE
• A detailed inventory of intended tariff options
• A description of future projects that may be developed/financed by the CCE
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Implementation Plan –What is required?
To meet pertinent requirements of the Public Utilities Code
(Code), the Plan must address the following elements:
• An organizational structure of the program, its operations, and its
funding.
• Ratesetting and other costs to participants.
• Provisions for disclosure and due process in setting rates and allocating
costs among participants.
• The methods for entering and terminating agreements with other
entities.
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Implementation Plan – Other required elements
The Code also specifies that the Plan address:
• The rights and responsibilities of program participants, including, but not
limited to, consumer protection procedures, credit issues, and shutoff
procedures.
• Termination of the program.
• A description of the third parties that will be supplying electricity under
the program, including, but not limited to, information about financial,
technical, and operational capabilities.
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Plan Contents & AB117 Compliance: MCE
AB 117 Requirement
Implementation Plan Chapter*
Statement of Intent
Process and consequences of aggregation
Organizational structure of the program, its
operations and funding
Chapter 1: Introduction
Chapter 2: Aggregation Process
Chapter 3: Organizational Structure
Chapter 4: Startup Plan and Funding
Chapter 7: Financial Plan
Chapter 8: Ratesetting
Chapter 9: Customer Rights and Responsibilities
Chapter 8: Ratesetting
Ratesetting and other costs to participants
Disclosure and due process in setting rates and
allocating costs among participants
Methods for entering and terminating agreements
Chapter 10: Procurement Process
with other entities
Participant rights and responsibilities
Chapter 9: Customer Rights and Responsibilities
Description of third parties that will be supplying
Chapter 10: Procurement Process
electricity under the program, including information
about financial, technical and operational capabilities
Termination of the program
Chapter 11: Contingency Plan for Program Termination
*Chapter numbers not reflected in this table provide ancillary information, not specifically required by AB117 but
useful to the CCE during its initial planning efforts as well as the CPUC while completing its document review. For
example, Chapter 5 addresses Program Phase-In; Chapter 6 addresses MCE’s Load Forecast and Resource Plan.
The organization of SCP’s 2013 (initial) iPlan was identical and substantially based on the MCE template.
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Implementation Plan Examples
• CPUC-Certified implementation plans have been submitted by
the following CCE programs:
• Marin Clean Energy (MCE)
• Sonoma Clean Power (SCP)
• Lancaster Choice Energy
• CleanPowerSF
• PCE’s Plan preparation would be expedited by utilizing a
previously certified document template – this is PCE’s intended
approach
• Template use may also expedite document review/certification
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Implementation Plan – Key PCE Decisions
• Before PCE’s Implementation Plan can be submitted to the CPUC,
the following items must be decided upon and reflected in the Plan:
• Initial JPA Membership: which communities are “in”?
• General description of PCE service offerings: default product, voluntary
green pricing option(s), and others, if applicable
• General description of PCE’s rate/pricing strategy: will PCE generally match
PG&E’s then effective schedule of customer rates or will there be substantial,
noteworthy differences?
• Identification of customer programs: NEM, FIT, EE and others, if applicable
• Customer enrollment: PCE must articulate its general plan for customer
enrollment (phases, schedule, targeted customer groups)
• Description of PCE’s organizational structure
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Key Plan Detail: MCE and SCP Examples
Topic
MCE’s Approach
SCP’s Approach
Process of
aggregation
Per law, automatic enrollment w/opt-out notices –
timing of opt-out notice distribution discussed for
first phase (March 2010); description of process
leading to CCE formation and launch also discussed
(Chapter 2)
Per law, automatic enrollment w/opt-out notices –
timing of opt-out notice distribution discussed for first
phase (February 2014); description of process leading to
CCE formation and launch also discussed (Chapter 2)
Organizational
structure and
operations
Description of organization, governance, leadership,
staff; roles/responsibilities described for each
organizational element; General Manager to operate
program under direction from Board; use of
committees contemplated on an as-needed basis;
formation of Energy Commission contemplated –
this Commission has not been created by MCE; brief
overview of JPA agreement and primary supply
agreement included; identification of initial staffing
requirements provided in tabular form (Chapter 3)
Description of organization, governance, leadership,
staff; roles/responsibilities described for each
organizational element; Chief Executive Officer to
operate program under direction from Board; specific
identification of Business Operations Committee and
Ratepayer Advisory Committee; major operating
functions to be managed by CEO are described,
including resource planning, finance and rates, etc.
(Chapter 3)
Startup plan and
funding
Identification of staffing requirements and
responsibilities during start-up, near-term and longterm operations (in tabular form); identification of
capital requirements, startup activities and related
cost summary for first 12 months in which costs will
be incurred (Chapter 4); additional detail in Chapter 7
Identification of startup activities and capital
requirements; indication that initial capital requirements
will be addressed via bank credit facility with cost
recovery to occur through SCP rates (Chapter 4);
additional detail in Chapter 7
Phasing
Three phases described, including customer
composition and timing; flexibility preserved based
on Board discretion; assumed account totals and
sales volumes disclosed for each phase (Chapter 5)
Three phases described, including customer
composition and timing; flexibility preserved based on
Board discretion; assumed account totals and sales
volumes disclosed for each phase (Chapter 5)
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Key Plan Detail: MCE and SCP Examples (cont.)
Topic
MCE’s Approach
SCP’s Approach
Load forecast and
resource plan
Ten-year resource plan described: initial
commitment to a minimum 25% renewable energy
content; mid-term goal of 60% renewable by 2015;
long-term (aspirational) goal of 100% renewable
energy supply articulated; plans to support 12 MW of
new distributed solar also identified; other supply
and programmatic goals described in general terms:
commitment to offering 100% green option; goal of
17% GHG reductions within Marin Communities;
energy efficiency; demand response; intention to
utilize long-term purchase agreements and,
potentially, direct resource investment (Chapter 6)
Key SCP resource planning policies described: increased
use of renewables and reduced reliance on fossil fuels;
creation of economic benefits through local investment
and program administration; resource diversity; cost
control, rate competitiveness and stability; and overall
cost reductions through efficiency enhancements and
demand reduction programs; initial commitment to a
minimum 33% renewable energy content; 50%
renewable content by 2018; use of local resources to the
greatest extent possible; availability of 100% green
option; quantified load reduction (1-2% annually)
through energy efficiency and demand response
(Chapter 6)
Rate setting
objectives
General: revenue sufficiency, stability, equity,
competitiveness, similarity to PG&E options and
support for NEM, FIT and green pricing; goal for
Light Green rates to be equivalent to similar rates
offered by PG&E (Chapter 8)
General: revenue sufficiency, stability, equity,
competitiveness, similarity to PG&E options and support
for NEM, FIT and green pricing; goal for standard tariff
(default service option) rates to be equivalent to similar
rates offered by PG&E (Chapter 8)
Customer rights
Restatement of opt-out process; identification of
termination fees for customers choosing to leave
after first two months of service – Administrative Fee
(fixed: $5 to $25) plus Cost Responsibility Charge
(variable – note that CRC has always been zero);
protection of confidential data (Chapter 9)
Restatement of opt-out process; identification of
termination fees for customers choosing to leave after
first two months of service – fixed fee ($5 for residential;
$25 for non-residential), no ongoing exit fees; protection
of confidential data (Chapter 9)
Procurement
Description of RFP process and short-listed suppliers
(3) (Chapter 10)
Description of RFP process and short-listed suppliers (4)
(Chapter 10)
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Key PCE Decisions: Detail
• Retails Service Options
• Define PCE’s default service offering (ex: minimum 50% renewable)
• Define any voluntary service offering(s) (ex: 100% Green option)
• Offering(s) should be characterized in a way that will ensure PCE satisfies
its objectives w/out compromising program launch; “pushing the needle”
to high may result in unachievable outcomes if markets change
• For example, MCE’s iPlan (2010) noted minimum 25% renewable content
at launch; SCP iPlan (2013) noted minimum 33% renewable content at
launch
• Both MCE and SCP specified 100% renewable tariff and NEM availability
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Key PCE Decisions: Detail (continued)
• Rate Setting
• Define PCE’s key rate setting principle(s):
• Example 1: PCE’s rates for the default service option shall be at or below similar
rates charged by PG&E at the time of program launch; and
• Example 2: PCE’s available rate options/structures shall generally resemble rate
options offered by PG&E (i.e., a customer currently served under PG&E’s E-1
rate option will remain on a similarly structured rate option following the
transition to PCE service)
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Key PCE Decisions: Detail (continued)
• Rate Setting
• Key rate principles should be clear, realistic, supportive of PCE’s objectives but
should also incorporate a reasonable amount of flexibility (in consideration of
prospective market changes)
• Example: a rate policy specifying that PCE rates will always remain 5% below similar
rates of the incumbent utility may compromise future program viability under
certain market conditions
• PCE will offer the cleanest possible power supply while promoting rate
competitiveness with PG&E
• CARE, FERA and Medical Baseline programs will remain available to PCE
customers (with discounts applied via T&D rate adjustments)
• Both MCE and SCP expressed a goal that default service rates would be
generally equivalent (and possibly lower) than the comparable rate offered by
PG&E
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Key PCE Decisions: Detail (continued)
• Complementary Energy Programs
• Identification of anticipated programs: energy efficiency, net energy
metering and feed-in tariff; any others?
• General characterization of program impacts to PCE operations: load
reduction, participatory limitations, etc.
• Per Code, specific details of such programs are not required to be reflected in
the plan – programmatic details can be described in specific tariffs, terms and
conditions, etc.
• Both MCE and SCP indicated:
• That a NEM service option would be available for participating customers
• That energy efficiency and demand reduction programs would be pursued,
including projected load reductions associated with such programs
• That local, distributed renewable resources would be supported through
programs/tariffs of the aggregation program
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Key PCE Decisions: Detail (continued)
• Program Phase-In
• What is PCE’s financial capacity to support program launch: capital + credit
• Other key phase-in considerations: 1) size (energy and customer count); 2)
geographic representation; and 3) customer groups
• Will PCE’s phase-in strategy be designed to promote overall financial
performance, diverse customer inclusion and geographic representation…
other considerations?
• Certain phase-in strategies may yield improved early-state financial
performance at the expense of broad customer representation
• Both MCE and SCP identified three-phase implementation approaches with
Board discretion to adjust phase-in options subject to various considerations
(market pricing, availability of supply, etc.)
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Key PCE Decisions: Detail (continued)
• PCE Organization
• Initial staffing
• Identification of responsibilities
• Outsourced functions/roles
• MCE and SCP identified the following details:
• General Manager/CEO would be appointed to oversee operations of the
aggregation program
• Staff and contractors would be engaged to support the GM/CEO in administering
program operations
• Committees could be formed to support specific areas of interest and decisions
• SCP specified creation of Business Operations Committee and Ratepayer Advisory
Committee
• MCE retained discretion related to committee formation but noted that an Energy
Commission might be formed (though this has yet to be done)
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Key PCE Decisions: Detail (continued)
• Identification of prospective Energy Services Provider(s)
• Supplier selection won’t likely occur in advance of Plan submittal
• Description of RFP process and short-listed respondents should satisfy
requirements of the Code (while ongoing negotiations and final supplier
selection occurs)
• MCE and SCP both generally described the solicitation/selection process
that was utilized to identify qualified energy services providers
• Identification of short-listed suppliers was included in the iPlan
• High-level detail regarding supplier qualifications and financial standing (credit
rating) was also included
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Key PCE Decisions: Detail (continued)
• Pro Forma
• Definition of key inputs: membership, resource mix and financing
requirements
• Run operating projections (in consideration of initial program operations)
for inclusion in Plan
• Both MCE and SCP provided pro forma financial projections in
consideration of anticipated customer enrollment, operational
expenditures, resource mix and other factors (Chapter 7 of iPlan)
• MCE and SCP also provided a summary of anticipated financing
requirements during early-stage operations; each program also indicated
the possibility of longer-term financing needs associated with direct
project investment
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Questions & Discussion